NOVEMBER 2006 CRA/HMDA Aggregate and Census Changes Disclosure Distribution Changes As announced by the Office of Manage- ment and Budget on December 5, 2005, T he collection of calendar institutions. Disclosure statements for Sebastian, FL now qualifies as a new principal city of the Vero Beach, FL Met- year (CY) 2005 Community each reporting institution and ag- ropolitan Statistical Area (MSA). Begin- Reinvestment Act (CRA), Home gregate disclosure reports for each ning with calendar year 2006 data, the Mortgage Disclosure Act (HMDA), MSA/MD and non-MSA/MD pre- title and MSA code for the Vero Beach, and Private Mortgage Insurance pared from the 2005 CRA data are FL MSA 46940 revised to Sebastian-Vero Companies of America (PMIC) data only available on the web at www. Beach, FL MSA 42680. is complete. The 2005 CRA, HMDA ffiec.gov/cra. Additionally, the CRA and PMIC aggregate report tables flat files that were formerly available The MSA title and code change will be and individual lender disclosure on the CD-ROM product are posted reflected on the 2007 FFIEC HMDA statements are now only available on the web so that individuals or (version 3.30) and 2007 CRA Data from the Federal Financial Institutions institutions may import the CRA data Entry Software (version 3.30). Since Examination Council (FFIEC) via into software packages for further the software will be valid for calendar years 2004-2007 data, users should The CRA flat files that were formerly available on the CD-ROM run the batch edit and error report, both located on the software application’s product are posted on the web so that individuals or institutions may “Front Page” prior to submitting data. import the CRA data into software packages for further analysis. The batch edit feature will display the total number of LAR records with validity the Internet at www.ffiec.gov. The analysis. The CRA flat files contain errors. The error report will identify all production of the aggregate the transmittal sheet, aggregate LAR records with validity errors when you tables and individual lender reports, and disclosure statements, choose the validity only option. Correct disclosure reports for all three and are found at http://www.ffiec. all validity errors identified on the error reporting series on CD-ROMs gov/cra/craflatfiles.htm. report prior to submission including all was discontinued beginning with loan application records with a property CY 2005 CRA, HMDA, and PMIC On September 8, 2006, the FFIEC location in the Sebastian-Vero Beach, data. member agencies – FRS, FDIC, OCC, FL MSA (i.e., any 2006 loans geocoded with MSA 46940 must be corrected to OTS, and National Credit Union reflect the new MSA 42680.) On July 25, 2006, four FFIEC agen- Administration (NCUA) – and the cies -- the Board of Governors of the Department of Housing and Urban Additional information regarding the Federal Reserve System (FRS), the Development (HUD) announced the MSA code change can be found on Federal Deposit Insurance Corpora- availability of 2005 HMDA data. the Statistical Programs and Standards tion (FDIC), the Office of the Comp- Financial institution disclosure state- page on the Office of Management and 1 CRAHMDA Reporter troller of the Currency (OCC), and ments and MSA/MD and nationwide Budget’s web site (www.whitehouse. the Office of Thrift Supervision (OTS) aggregate reports are only available gov/omb). -- announced the availability of 2005 on the FFIEC web site at www.ffiec. CRA data as reported by certain gov/hmda. (The HMDA Loan Ap- commercial banks and savings contiued on p. 6 Type of Purchaser (TOP) Coding Issues Easy ways to search the HMDA Guide online T he type of purchaser (TOP) field on the HMDA-LAR identifies the type of secondary market entity that originated or purchased loans were sold to within the same calendar year. We have revised or While it is advisable to print expanded some of the entity types that an institution may sell these the document in order to have loans to; for example, private securitization (code 5), mortgage bank a paper copy on hand, there (code 7) and finance company (code 7). We have also included spe- are several useful advantages cific questions and answers about when to use these codes at the fol- to using the electronic version lowing web site (http://www.ffiec.gov/hmda/faqreg.htm). These FAQs of the HMDA Guide. are worth reading and familiarizing yourself with accurate reporting of the TOP field. The updated 2006 version of A Guide to HMDA Reporting: Get- It is important that your institution be prudent in selecting the correct ting it Right is now available ex- code for loans that are sold within the same calendar year. A report- clusively on the web (http://www. ing problem was uncovered in the 2005 data during the data quality ffiec.gov/hmda/pdf/2006guide. assessment period whereby a couple institutions should have reported pdf). While it is advisable to print their sold loans using a TOP code of 5 and not 3. They did not sell the document in order to have a directly to Freddie Mac; they sold to an institution that securitized the paper copy on hand, there are loans and one of the purchasers of the securitized loans was Freddie several useful advantages to us- Mac, which caused the reporting institutions to think that they sold the ing the electronic version of the loans to Freddie Mac. However, that was not the case and their data HMDA Guide. were corrected. • The ‘Bookmarks’ tab on the left Other important reminders regarding the reporting of TOP: side of the screen provides a view of the overall organization Report zero (0) in the TOP field in the following situations: of the document and convenient one-click access to a desired • Loan was originated but not sold in the calendar year covered by section. the HMDA-LAR activity year; • The search function (obtained • Loan was purchased from another entity but not sold in the calen- by clicking the binoculars icon dar year covered by the register; or or right click ‘Search’) allows the user to investigate a specific • Application was denied, withdrawn, approved but not accepted by search criterion. This search the applicant; or closed for incompleteness. method is effective because a search window appears and If you sell loans to more than one purchaser, use the code for the displays the total search results entity purchasing the greatest interest. accompanied by the page num- ber and subject context. If you sell only a portion of the loan, retaining a majority interest, do not report the sale. • The final search method is ‘ctrl- f’ which manually takes the user If you sell originated or purchased loans at a later time in the same from one key word to the next calendar year covered by the HMDA-LAR activity year, collect the throughout the document. TOP information and update the field on your HMDA-LAR to reflect the sale of the loans; also make sure that the correct TOP data are Please familiarize yourself with this submitted in your file. material. After all, most inquiries from the public to HMDAHELP or If you sell originated or purchased loans in a succeeding year, do the HMDA assistance lines are an- 2 CRAHMDA Reporter not report the loan sale on that year’s LAR. Additionally, do not go swered by analysts whose primary back and update the TOP column on the LAR for the year in which resource is the Guide itself. Be- the loans were originated or purchased; in this case the type of pur- come your own HMDA expert by chaser will never be reported. learning how to effectively navi- gate the HMDA Guide! FFIEC Geocoding/Mapping System CRA Regulation Changes A re you receiving an Address uses to map street addresses is cur- In August of 2005, the Federal Re- Not Found when attempting rent only to certain dates, and street serve Board, the FDIC, and the OCC to retrieve the Metropolitan addresses added after that date will collectively raised the asset thresh- Statistical Area/Metropolitan Division not be located. Even after a new old for large institutions from $250 (MSA/MD), State, County, and Cen- update is received, it is possible that million to $1 billion (70 FR 44256). sus Tract combination from the FFIEC an address will not be included in the This follows a similar regulatory Geocoding/Mapping System (The database and thus geocoding infor- change implemented by the OTS in System)? If so, make sure you are mation will not be found. In these 2004. Institutions not meeting the following the system requirements. cases, you should use census tract new large institution asset threshold maps and other tools available from requirements are no longer obligated The System allows you to retrieve the U.S. Census Bureau. to report their annual CRA data to MSA/MD, State, County and Census the Federal Reserve Board. In addi- Tract combinations for street ad- When an address is not found, use tion, the holding company affiliation dresses. It is primarily intended to the mapping feature. The System is no longer a factor in determining assist financial institutions covered by will display an area street map based whether an institution is required to the Home Mortgage Disclosure Act on the combination of street address submit CRA data. (HMDA) and Community Reinvest- and zip code, OR street address, city ment Act (CRA) to meet their report- and state. A red triangle will mark Institutions that do not meet the new ing obligation. The system is also the center of the zip code area on the asset criteria of large institutions still helpful in obtaining census demo- map (not the location of the prop- have the option of reporting CRA graphic information on population erty). Click on the map and zoom data on a voluntary basis. Those and income data. in/out to locate the cross streets for institutions, who submit their CRA the address and identify a census data to the Board by the March 1st To render a successful result, you tract code. The mapping feature deadline, retain the option of being must enter a street address along may not appear in all cases. For examined as a large institution even with a city and state OR a zip code. example, if you enter an invalid state if they did not meet the asset thresh- All four fields do not need to be com- and zip code combination or an in- old of $1 billion. However, by not pleted; however, the street address valid city and state combination, you reporting CRA data by the March 1st must be entered and accurate. For will receive an Address Not Found deadline, an intermediate or small example, if the address includes the with no mapping feature available. institution sacrifices the option of be- word “street,” use that word; do not ing examined as a large institution. enter the address using words like It is critical that you follow The Sys- “avenue” or “boulevard.” Also, do tem requirements to prevent prop- not include apartment numbers with erty location validity errors on your For additional information on the the street number and address. The HMDA report. If the FFIEC Geo- regulation changes please visit the correct city and state OR zip code coding System does not provide the following web page. should be included for the street ad- geographical information about the http://a257.g.akamaitech.net/7/257/ dress. The System will not geocode property location, there are several 2422/01jan20051800/edocket.access. .O. P Boxes or Rural Routes. Once other tools that can be used (refer to gpo.gov/2005/05-15227.htm you have entered the correct address pages 18-21 of the Guide to HMDA information in the appropriate boxes, Reporting: Getting it Right!) to geo- For additional information regarding click on the ‘Search’ button to obtain code your data. It is the institution’s CRA examination procedures of small, the geocoding information. responsibility to exhaust all available intermediate, and large institutions resources to obtain valid property please go to the following web page. The System may not provide prop- location information. In any case, http://www.ffiec.gov/cra/examinations.htm erty location information for all valid if your institution has exhausted all street addresses. While this should your resources and questions re- 3 CRAHMDA Reporter For other CRA-related inquiries, please not occur often, it is normal because main, please feel free to contact contact the CRA Assistance Line at the geocode database that the FFIEC firstname.lastname@example.org. (202)872-7584, or send an email to email@example.com HMDA Data Entry Software Version 3.30 HMDA Data Entry Software Version Version 3.30 for CY 2007 data col- Beginning with calendar year 2006 3.30, for the collection and report- lection contains several 2006 edit data, the title and MSA code for the ing of CY 2004 through CY 2007 updates which are listed below. All Vero Beach, FL MSA 46940 revised data, is scheduled for release in users should download the most to Sebastian-Vero Beach, FL MSA December 2006. Version 3.30 will current version in order to reflect all 42680 (Refer to Census article in only be available by download from updates in your 2006 HMDA submis- this newsletter). Run an error report the FFIEC web site (http://www.ffiec. sion file. Your HMDA data must be and correct all loan application re- gov/software/default.aspx). The free edited prior to submission using the cords with a property location in the software includes editing features to FFIEC HMDA edits (http://www.ffiec. Sebastian-Vero Beach, FL MSA (i.e., help you verify and analyze the ac- gov/hmda/edits.htm). Regulation C any 2006 loans geocoded with MSA curacy of the reporting data. requires all HMDA data submissions 46940 must be corrected to reflect to be free of validity errors prior to the new MSA 42680.) Utilize the The data file created using the submission. You must submit a valid- Global Modify feature located under FFIEC software must be encrypted ity-free submission or your institution the Edit Menu on the Front Page of for submission via Internet e-mail or is at risk of noncompliance. the software. See Help for more exported onto a diskette/CD-ROM details. for mailing. Deleted Edits END-OF-CYCLE Macro Quality Edits (CONT’D) V405 Replaced with Q059 (See New Edits). Q056 Checks that the total number of denied conventional home V380 Replaced with Q060 (See New Edits). purchase loans is ≤ 70% if the total number of conventional home purchase loans is ≥ 50. New Edits Q057 Checks that the total number of denied loan applications Q050 Checks for valid HOEPA status code is Agency = 5 (NCUA). is > zero if the total number of loan applications is ≥ 50. Q051 Checks for valid HOEPA status code when applicant ethnicity, Q058 Checks that the total number of preapproval requests denied race and sex = 4, 7, and 4 respectively. is > zero if the total number of loan applications where Q052 Checks for valid HOEPA status code when property type = 3. preapproval = 1 is ≥ 1000. Q059 Checks for valid property type if loan type = 3 or 4. Q061 Checks that the total number of originated loans (action taken Q060 Checks for valid date application received. type =1) where property type = 1, lien status = 1, and rate Q061 Checks for valid rate spread when Agency = 5 (NCUA), spread > 5% and not = NA is ≤ 1% of the total number of property type = 1, lien status = 1, and action taken type = 1. originated loans. (Note: End-of-Cycle Macro Edit Q061 Q062 Checks for valid HOEPA status when action taken = 1, includes Agency 1, 2, 3, 4, 5, and 7) HOEPA status = 1, lien status = 1 and purchaser type = 1. Q062 Checks that the total number of originated loans (action taken Q063 Checks for valid HOEPA status when action taken = 1, type = 1) where HOEPA status = 1, lien status = 1 and HOEPA status = 1, lien status =1 and type of purchaser = 3. purchaser type = 1 is ≤ 1% of the total number of originated loans. END-OF-CYCLE Macro Quality Edits Q063 Checks that the total number of originated loans (action taken Q053 Checks that the total number of originated loans (action taken type = 1) where HOEPA status = 1, lien status = 1 and type = 1) where agency = 5 and HOEPA status = 1 is ≤ 1% purchaser type = 3 is ≤ 1% of the total number of originated of the total number of originated loans. loans. Q054 Checks that the total number of purchased loans (action taken type = 6) where agency = 5 and HOEPA status = 1 is ≤ 1% Revised Edits of the total number of purchased loans. Q030 Edit test modified to remove CRA asset test. Q055 Checks that the total number of originated loans (action taken S100 Edit test language modified to check for valid activity year. = 1) where HOEPA status = 1 and rate spread ≥ 5% and Q044 Edit test modified to exclude Agency 5. not = NA, is ≤ 5% of the total number of originated loans. Q045 Edit test modified to exclude Agency 5. In addition, if you utilize third-party HMDA Data Entry Software by using option for submitting your HMDA vendor software for HMDA data the editing and reporting features. data. Submit your 2006 valid en- 4 CRAHMDA Reporter collection and reporting, you should crypted HMDA data file via e-mail take advantage of the benefits of the Sending your submission via Internet to firstname.lastname@example.org on or before e-mail remains the most efficient March 1, 2007. Relieve Stress & Increase Efficiency - - Submit via Internet E-mail J oe and Mary are siblings as (2) Import (or manually enter) the Board prior to the specified due well as bankers who both HMDA data into the DES; date. It is now March 1st and filed their bank’s HMDA-LAR (3) Perform a batch edit to identify Mary is leaving early for the day. on February 26th, just shy of the any validity errors and qual- March 1st due date; however, ity edits; (All data with validity For Joe, however, life is not so the similarities end here. You errors must be corrected prior easy. Delayed by additional post- see, Joe filed his HMDA data to submission; data with qual- al security checks, his paper copy the same way he always has--by ity edits should be verified and submission has not yet arrived at submitting a hand-written paper corrected if necessary) the FRB’s HMDA Operations of- copy via postal mail without using (4) Export/create an encrypted file fice. Even though his submission the HMDA Data Entry Software submission (hmdaencr.enc); will be on time because it was (DES). Mary, in contrast, decided (5) E-mail to email@example.com postmarked prior to the March she would try the recommended 1st deadline, Joe is worried that method of submitting her report Shortly after submitting the his submission has not yet arrived via e-mail. This was the first HMDA-LAR via e-mail, Mary (unlike Mary, he receives no im- year Mary decided to follow the receives an e-mail response mediate confirmation of receipt). five simple steps of submitting confirming the receipt of her Furthermore, there is a possibility electronically: submission. Upon receiving her that he will have to correct data edit report, Mary again checks the containing validity errors on an (1) Download the free FFIEC accuracy of the data containing edit report that should be sent to HMDA Data Entry Software quality edits, signs and dates the him at a future date. After all, he (DES), http://www.ffiec.gov/ confirmation sheet, and faxes the did not run the data through any hmda/softinfo.htm; required documentation to HMDA edits. Operations at the Federal Reserve The moral of this story is that when done properly, submitting via Internet e-mail is the best way to go! Here are some of the excellent reasons why… 10 No calls/trips to the mail carrier to overnight the diskette/CD-ROM or paper copy reports. 9 No shipping/postage fees. 8 No sleepless nights wondering if the bank’s HMDA report was lost in the mail. 7 No additional trips to the mail carrier to overnight resubmissions or missing diskettes/CD-ROMs. 6 Immediate confirmation that the submission has been received. 5 Quicker turn-around for edit reports/corrections. 4 No lost or damaged diskettes/CD-ROMs or paper copy reports. 3 Validity error-free data are submitted--Data must contain no validity errors before the DES software will allow the encrypted ENC file to be created and sent via Internet e-mail. 2 Everybody’s doing it! (Over 95% of reporters submitted via Internet e-mail during the calendar year 2005 data processing season) And the Number ONE reason for submitting via Internet e-mail is... 5 CRAHMDA Reporter 1 E-mails are the most efficient method—the encrypted ENC file is received via e-mail, reviewed and usually loaded within the same day. contiued from p. 1 plication Register (LAR) & Transmittal statement available at one branch at www.ffiec.gov/reports.htm (The Sheet (TS) raw data product, howev- per MSA or provide a copy upon PMIC LAR and TS raw data product er, continues to be available on CD- written request. is available on CD-ROM; for product ROM. For availability of this product availability and ordering instructions, and to order it from the FFIEC, refer The FFIEC also provides PMIC data refer to www.ffiec.gov/hmda/order- to www.ffiec.gov/hmda/orderform. collected from the nation’s eight form.htm). htm)). private mortgage insurance compa- nies. The PMIC data include infor- If you have any questions about Financial institutions are required mation on applications for mortgage an aggregate or disclosure report, to make their disclosure statements insurance. The 2005 PMIC disclo- please e-mail us at hmdahelp@frb. available at their home offices; and, sure statements and MSA/MD and gov. for other MSAs in which they have nationwide aggregate reports are offices, to either make a copy of the only available on the FFIEC web site BULLETINBOARD NEED ASSISTANCE? FFIEC For further assistance with CRA and HMDA, visit the following web sites, send Reporting an e-mail, or call the phone numbers listed below: CRA R E S O U R C E S http://www.ffiec.gov/cra firstname.lastname@example.org (202) 872-7584 Below is a list of the more popular FFIEC reporting publications and filing resources available on the HMDA http://www.ffiec.gov/hmda FFIEC CRA and HMDA web sites. email@example.com (202) 452-2016 CRA HMDA CRA Aggregate Reports HMDA Aggregate and ALERT: Disclosure Reports Revised 2005 HMDA CRA Disclosure Reports Disclosure Statement Frequently Asked Questions (FAQs) Deadline Interagency Questions & Answers FFIEC HMDA Data Entry Software 2005 HMDA resubmissions warranting FFIEC CRA Data Entry Software a revised disclosure statement will be FFIEC Geocoding System accepted up to February 27, 2007. FFIEC Geocoding System We strongly recommend that institutions FFIEC Rate Spread Calculator e-mail their HMDA resubmissions to How to File firstname.lastname@example.org for expedited How to File processing. Institutions will receive a 6 CRAHMDA Reporter Where to Submit 2005 Edit Report for their review and confirmation. A revised copy of the dis- Where to Submit closure statement will be provided to the institution. Resubmissions of 2005 data received after this date will be processed but a revised disclosure statement will not be available. Mergers and Acquisitions: CRA Data Entry Software How and when to report HMDA data The next scheduled release of the FFIEC CRA Data Entry Software, Ver- If your institution was involved in a structure change: i.e., a merger or acqui- sion 3.30, will be available for down- sition, there is a good chance that change may affect how and when your load from the FFIEC CRA web site in institution should report their HMDA data. In any case, you should contact Fall 2006. The software is free and email@example.com and inform them of the change, and how you will submit can be utilized for editing, reporting, your HMDA data for the year of the merger and subsequent years. Below are and submission purposes. five examples of situations that may occur. Additionally, several software fea- Two institutions merge, producing a successor institution whose assets tures may be useful in the process of exceed the asset threshold for coverage. Both were previously exempt collecting and reporting CRA data. because of asset size. The successor institution’s first HMDA data collection These include data quality checks, will be for the calendar year following the year of the merger. No data col- analysis reports, and optional loan lection is required for the year of the merger. categories that institutions may use in collecting data for consideration in a Two institutions merge, one covered and one exempt. The covered insti- CRA exam. tution is the surviving institution. For the year of the merger, data collec- tion for loan applications, originations, and purchases is required for the Version 3.30 will also include an covered institution’s transactions and is optional for transactions handled in enhancement to the Batch MSA/MD offices of the previously exempt institution. Change feature in the Edit func- tion. This feature will enable users to Two institutions merge, one covered and one exempt. The exempt institution update an MSA/MD code for multiple is the surviving institution, or a new institution is formed. Data collection for loan application registers (LARs) in a loan applications, originations, and purchases is required for transactions of single screen. With the older versions the covered institution that take place prior to the merger. Data collection is of the software, users had to manually optional for transactions taking place after the merger date. update the MSA/MD code on every applicable LAR, a potentially time- Two covered institutions merge. The surviving or resulting institution must consuming effort. However, with this report complete data for the year in which the merger occurred; the institu- enhanced feature, users would use a tion has the option of filing a consolidated report or separate reports for four-step process to revise or update that year. an MSA/MD code across multiple LARs: • If the institutions reported to different agencies before the merger, the re- 1. From the Edit menu on the CRA ports for the year in which they merged and all subsequent reports must Front Page, click on Batch MSA/ be submitted to the agency designated by the supervisory agency of the MD Change surviving or resulting institution to receive that institution’s data. 2. Check the box next to “Change Specific MSA/MD?” If the surviving covered institution is regulated by an agency different from 3. Input both the old and new MSA/ the agency regulating the covered non-survivor, and the surviving institu- MD codes in the appropriate boxes tion chooses to file separate reports, the surviving covered institution files 4. Click Begin their report using their specific respondent ID number and agency code. However, the surviving institution uses an altered RID number along with the The software will then replace the survivor’s agency code when filing the non-survivor’s report. The non-sur- old code with the new one in all of vivor’s old RID number is altered by replacing the leading three zeros with the applicable LARs. For example, if “99-“. This identifies that the data is from a non-survivor filing separately. a user has small business and small farm LARs in their data entry software In the situation where neither a merger with nor an acquisition of an institu- system that are geocoded with the old tion, nor an acquisition of a branch, is involved, and the covered institution MSA/MD code for Vero Beach, FL purchases HMDA-related loans in bulk from another entity (for example, (46940), they can use this enhanced from a failing institution), the purchasing institution must report those loans feature to revise their LARs to reflect 7 CRAHMDA Reporter as “purchased loans.” the new MSA/MD code for Sebas- tian–Vero Beach, FL (42680). [This This list of situations is not all inclusive; if your institution has a specific ex- code change was announced by the ample and would like guidance, please feel free to contact hmdahelp@frb. Office of Management and Budget on gov. December 5, 2005]. Resubmitting HMDA Data Guidelines What is an Agency Code? An agency code is a one-digit number An institution is expected to submit valid and accurate HMDA data that have been that represents the regulatory agency that checked using edits approved for the particular calendar year. Effective January 1, 2006, a processing procedural guideline was changed with regards to complete supervises your institution. The codes resubmissions. If an institution is to resubmit its data, it should send a complete are as follows: resubmission; it should not send partial resubmissions. A couple exceptions to the Office of the Comptroller rule are: of the Currency (OCC) 1 Federal Reserve System (FRS) 2 LAR count is greater than 350,000 records Institutions that submit HMDA-LAR containing more than 350,000 records may Federal Deposit Insurance request a maximum of 10 manual corrections via fax, e-mail, or telephone, per Corporation (FDIC) 3 submission. If a subsequent edit report from a file requires more than 10 corrections, Office of Thrift Supervision (OTS) 4 the institution should send a complete resubmission. National Credit Union Administration (NCUA) 5 Paper submission with 25 or fewer LAR records A HMDA-LAR submitted on paper is accepted from institutions reporting 25 or fewer Department of Housing and loan records. If 10 or fewer errors are found in the edit report of a paper submis- Urban Development (HUD) 7 sion, the institution may request manual changes via fax, e-mail, or telephone. If the subsequent edit report from a paper submission contains more than 10 corrections, What is a Respondent Identification the institution should send a complete resubmission. (RID) Number? A RID number is a ten-digit number; If you are resubmitting, then, after you correct your data, follow the same steps you the numbers for depository institutions would in creating your initial submission (batch edit, export data, transmit data, re- require leading zeros to meet the length ceive and resolve edit report, and sign off on the confirmation sheet). requirement. The RID number is derived from different agency identifiers. A RID Transmit the entire corrected file via Internet e-mail, CD-ROM, or diskette. Clearly mark your resubmission as a “Complete Resubmission of CCYY data.” Also include number, along with the agency code, the reason for your resubmission along with the other information asked for in the In- ties the number to a specific agency and ternet e-mail, diskette, or CD-ROM file specifications (for example, institution name, institution. The identifiers for depository respondent ID number, agency code, processing year, contact name, phone number, institutions include: LAR count being transmitted). OCC - charter number FRS - RSSD number Reasons for a resubmission include changes to: LAR count; MSA/MD; respondent FDIC - certificate number name; RID number and/or agency code; loan type; property type; loan purpose; OTS - docket number 10% or more of data, 100 or more records, etc. It is also helpful if you include NCUA - charter number whether the changes resulted from an internal audit or an exam. The identifiers for nondepository If you choose the Internet e-mail option to transmit your data, send a complete resub- institutions include: mission to firstname.lastname@example.org. If you choose the diskette or CD-ROM option, mail FDIC, OCC and NCUA - federal tax ID number (preferably overnight) the file to: with the hyphen OTS - federal tax ID number without the hy- Federal Reserve Board phen and with a leading zero Attention: HMDA Processing, (Enter Agency OCC, FDIC, OTS, NCUA or HUD) FRS - RSSD number 20th and Constitution Avenue, NW HUD - federal tax ID number with the hyphen MS N502 In addition to including your RID number Washington, DC 20551-0001 and agency code on your transmittal FRS resubmission addresses are available at www.ffiec.gov/hmda/contactFRS.htm. sheet, input them in the subject line of your email (or on your diskette) when If the resubmission is received after the databases are closed for the annual disclo- submitting HMDA data. If you have sure and aggregate reports generation, the resubmitted file is processed when the reported in the past, please continue to databases reopen (usually during late June/early July). If the resubmission covers the use your assigned RID unless otherwise 8 CRAHMDA Reporter current activity year being processed and your disclosure statement is re-created, the instructed by HMDA Operations staff. disclosure statement will be re-created and mailed to you for public disclosure after If a merger or acquisition occurred re- the current activity year’s HMDA data are released to the public (usually occurs in cently and you are unsure about the RID early September). The publicly-released versions of the disclosure statement found number and agency code to use, e-mail on the FFIEC HMDA web site cannot be updated. In addition, the HMDA Raw Data email@example.com with details. Software on CD-ROM cannot be updated. Phases of Editing Micro, Macro, End-of-Cycle, Data Quality Assessment Each year, prior to the public release and resolved as needed. The data rect, the records should be corrected of HMDA data, a series of edits are with validity edits should have been and a complete resubmission should performed to ensure data quality, corrected. Therefore your review of be sent within a few business days. integrity and accuracy of reporting. the edit report documents, and the Although the timeframe to respond Your data are run against the HMDA completion and faxing back of the to these edits is short, it is reasonable edits several times from January 1 (if necessary documents and confirma- because institutions are expected to you submit your data that early) and tion sheet can generally be complet- know their data with respect to all mid- to late May. ed the same day that the edit report HMDA edits. was faxed. Micro Editing -- A full description of Data Quality Assessment Editing – the edits including the edit test and Macro and End-of-Cycle Editing – The fourth and final phase of edit- error explanation is available in the The edit document includes macro ing occurs over the first three weeks HMDA edit document, http://www. quality edits and end-of-cycle qual- in May during the data quality ffiec.gov/hmda/edits.htm. The ity edits, which are considered the assessment period. Other agency document contains numerous trans- second and third phases. An institu- economists, researchers, and analysts mittal sheet and loan/application tion’s entire LAR file must be received generate reports and complete com- record “micro” edits. These edits before these macro edits can be parisons of current to previous years’ are included in the FFIEC Data Entry performed because we compare cur- data. Loans sold to the secondary Software (DES), http://www.ffiec. rent and previous years’ totals and market, pricing data, HOEPA and gov/hmda/softinfo.htm, as well as percentages, or current year’s total lien status information are among in the FFIEC mainframe database LARs against the number of loans some of the areas that are checked editing program. Thus, your data where a particular action was taken, again. If institutions are to be con- goes through the same edits when type reported, or purpose reported. tacted, they will be called; immediate it is loaded to the FFIEC mainframe For example, a few areas we check attention and resolution is requested. database. Following the process- are: If a corrected resubmission is neces- ing, an edit report is faxed to you for sary, the resubmission should be sent review and resolution. • Current year’s number and per- in 1-2 business days. centage of loans sold to the sec- By adding these edits to the FFIEC ondary market in comparison with These four phases of editing continue DES, it provides you with a way to previous year sales; to be necessary. For the past sev- easily check your HMDA-LAR us- • Income and loan amounts for pat- eral years we have identified a small ing edits approved for the particular terns of possible incorrect report- number of institutions in the fourth calendar year and meet the FFIEC’s ing; and editing phase whose data was incor- expectations of your institution sub- • Number or percentage of denials rectly reported. The edit document mitting valid and accurate data. The reported based on the total LARs changes a bit every year. Familiarize batch edit function on the software reported. yourself with the edit tests and error allows you to review and correct your explanations of the micro, macro, data prior to submission. (Data with The results of the macro editing and and end-of-cycle edits. Check your validity errors must be corrected; end-of-cycle reports are analyzed to HMDA data against the edits ap- data with warnings -- quality edits determine the institutions that should proved for the particular calendar -- should be reviewed and corrected, be contacted based on other factors year to ensure that you are submit- if necessary). such as institution size, institution ting valid and accurate data. location, how large the tolerances Another advantage to using the DES are, etc. These two editing phases We hope this article provides insight batch edit function is that when the are usually performed in late March to the complete HMDA editing pro- 9 CRAHMDA Reporter edit report is faxed to you after your through April. Institutions are con- cess, and in case HMDA staff con- data have been loaded to the FFIEC tacted by HMDA processing staff via tact your institution in April or May database, the only edits that should faxes, e-mails, and telephone. If the requesting a “quick” data review and appear on the edit report are qual- data are valid, a brief explanation response, you will be able to respond ity edits that you already reviewed is requested. If the data are incor- quickly.
Pages to are hidden for
"Vero Beach Fl Bank with Online Mortgage Application - PDF - PDF"Please download to view full document